S.D.N.Y.
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This document is page 165 of a legal filing (Document 204) from April 2021 in the case against Ghislaine Maxwell (Case 1:20-cr-00330). The prosecution argues against the defendant's motion to sever Counts Five and Six, stating that the perjury charges and sex abuse charges are logically connected by a common scheme. The text cites Federal Rule of Criminal Procedure 8(a) and various case precedents to support the joinder of offenses.
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This legal document, a page from a court filing, discusses the legal standard for materiality in a perjury case. It cites several precedents (Gaudin, Kross, Birrell, Chan Lo) to define what constitutes a material false statement, particularly in the context of a deposition. The document concludes by arguing that the defendant's deposition statements were knowingly false and that the determination of their truthfulness is a matter for the jury at trial, not for a pretrial dismissal.
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This document is a page from a legal filing, specifically a memorandum of law, discussing the legal standards for perjury. The author argues against dismissing a perjury count before trial based on 'fundamental ambiguity,' citing numerous court cases to establish that such challenges are typically evaluated after a trial. The text distinguishes between answers that are literally true but misleading (which may not be perjury) and answers that are outright false, regardless of responsiveness (which can be perjury).
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This document is page 143 of a legal filing by the Government in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on April 16, 2021. The text argues against granting the defendant an evidentiary hearing regarding a 'Franks' analysis and asserts that the defendant failed to meet the burden of proof to obtain discovery or dismiss perjury counts. The Government contends that a jury should decide whether the defendant committed perjury during two depositions in a prior civil matter.
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This legal document, a page from a court filing dated April 16, 2021, discusses the legal standard for challenging an affidavit based on alleged omissions of fact. It cites numerous precedents, primarily from the Second Circuit and the Southern District of New York, to argue that a motion to suppress evidence should be denied unless the omissions were intentional, deliberate, or made with reckless disregard for the truth. The document emphasizes that this is a high standard to meet, as courts recognize that all affidavits will inevitably omit some facts that may seem significant in retrospect.
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This legal document, page 140 of a court filing from April 16, 2021, outlines the legal standard for a defendant to obtain a "Franks hearing" to challenge the validity of an affidavit used for probable cause. It details the three-part test a defendant must meet, requiring a "substantial preliminary showing" of inaccuracies or omissions in the affidavit that were material and made with deliberate falsehood or reckless disregard for the truth. The document explains that a court must then determine the materiality of these errors by revising the affidavit to see if it still supports a finding of probable cause.
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This document is a page from a legal filing, specifically outlining the applicable law concerning the Due Process Clause of the Fifth Amendment. It defines and distinguishes between procedural and substantive due process by citing several court cases, including Martinez v. McAleenan and United States v. Salerno. The text highlights the two-step analysis for procedural due process and notes the Supreme Court's reluctance to expand the concept of substantive due process, as stated in Washington v. Glucksberg.
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This document page is from a legal filing in the case United States v. Ghislaine Maxwell (1:20-cr-00330). The text presents a legal argument distinguishing the current case from *United States v. Oshatz*, specifically regarding the enforceability of subpoenas for deposition transcripts and protective orders. It cites Chief Judge McMahon's finding that the Government demonstrated 'extraordinary circumstances' justifying the modification of a protective order, unlike in *Oshatz* where the government was characterzied as 'trolling for evidence'.
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This document is a page from a legal filing, likely a government brief, arguing against a defendant's claim of Fifth Amendment privilege. It cites numerous court cases (such as Boyd, Fisher, and Bryson) to establish that the act of production privilege for private papers has been limited and that the Fifth Amendment does not protect an individual from prosecution for perjury, even if testimony was improperly compelled. The core argument is that a citizen cannot lie to the government with impunity.
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This legal document page outlines the Fourth Amendment's third-party doctrine, which generally holds that individuals have no reasonable expectation of privacy in information voluntarily shared with third parties. It cites key Supreme Court cases like Miller and Smith to support this doctrine, while also discussing the narrow exception for cell site location information established in the Carpenter case. The document concludes by emphasizing that a defendant bears the burden of proving, through sworn evidence, that their own rights were violated to have standing to challenge a search.
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This document is page 106 of a legal filing (Document 204) in the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on April 16, 2021. The text details the Government's argument that it did not circumvent the 'Martindell' legal standard when seeking evidence previously under protective orders, specifically referring to a subpoena issued to the law firm Boies Schiller. It notes that Judges McMahon and Netburn ruled that the Government had demonstrated 'extraordinary circumstances' justifying the release of testimony to the grand jury despite previous protective orders.
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This document is a page from a legal filing in which the prosecution (Government) argues against a motion by the defendant, Maxwell, to dismiss her indictment due to pre-indictment delay. The Government cites several legal precedents (Pierre-Louis, Burke, Carbonaro) to argue that the defendant has failed to show the delay was improper or for a tactical advantage. The document also addresses Maxwell's specific claim that the Government delayed the indictment to benefit from a separate civil litigation involving Giuffre, a claim the Government refutes.
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This page is from a legal filing (Document 204) in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). The Government argues that the Defendant failed to prove the Indictment was delayed for an improper purpose. The text discusses the legal standards for pre-indictment delay, citing Supreme Court and Circuit precedents, and rejects the Defendant's request for a 'balancing test' regarding prejudice.
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This legal document is a portion of a filing by the prosecution (The Government) arguing against a defendant's motion to dismiss an indictment. The prosecution contends that the defendant's claim of prejudice due to a delay in prosecution is speculative, as her assertions about diminished witness memories and lost access to her own emails, phone, and travel records from 1994-1997 lack proof of their helpfulness or materiality. The document cites legal precedents (Harrison and Dornau) to support the position that such speculative claims are insufficient grounds for dismissal.
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This legal document is a page from a court filing that refutes a defendant's argument about the legislative intent of Section 3283. The author argues the defendant used a misleading, selective quote from Senator Patrick Leahy to claim Congress did not intend for an extended statute of limitations to apply retroactively. The document provides the full quotation to show that Congress removed the retroactivity provision due to constitutional concerns, not to limit the statute's application as the defendant suggests.
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This legal document is a portion of a court filing arguing against a defendant's motion for an evidentiary hearing. The author contends that the defendant has failed to provide sufficient evidence, such as affidavits, to establish a genuine factual dispute that would warrant a hearing. The filing contrasts the current defendant's lack of evidence with several precedent cases (Aleman, Sattar, Feldman) where hearings were granted because defendants submitted supporting affidavits or made uncontested assertions.
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This document is page xxiv of a legal filing from Case 1:20-cr-00330-PAE, filed on April 16, 2021. It is a table of authorities, listing numerous legal case citations with corresponding page numbers where they are referenced within the larger document. The majority of the cases listed involve the United States as a party against various individuals and one corporation.
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This document is page 24 of a legal filing (Case 1:20-cr-00330-PAE, Document 204) filed on April 16, 2021. It is a table of authorities listing numerous legal cases, primarily with the United States as the plaintiff, along with their full legal citations and the page numbers where they are referenced in the main document. The cases cited are from various federal courts and span several decades, serving as legal precedent for the arguments made in the filing.
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This document is page xxi from a legal filing in case 1:20-cr-00330-PAE, filed on April 16, 2021. It serves as a table of authorities, listing various legal precedents in the format 'United States v. [Defendant]'. Each entry includes the case citation and the corresponding page numbers where it is referenced within the main document.
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This document is page 21 of a Table of Authorities from a legal filing (Document 204) in Case 1:20-cr-00330-PAE, which corresponds to the trial of United States v. Ghislaine Maxwell. The page lists various legal precedents (case law citations) ranging from 'United States v. Rahimi' to 'United States v. Rosa' used to support legal arguments in the main brief. The document bears the Bates stamp DOJ-OGR-00002955.
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This document is page 15 of 239 from a legal filing in case 1:20-cr-00330-PAE, filed on April 16, 2021. It is a table of authorities, listing various United States court cases from 'Falso' to 'Gracesqui' along with their legal citations and the page numbers where they are referenced within the larger document.
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This document is page 10 (labeled 'ix') of a Table of Authorities from a legal filing dated April 16, 2021, in the case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell). It lists legal precedents beginning with 'S' through 'U', including citations for *United States v. Nader* (marked 'passim', meaning cited frequently) and various Second Circuit decisions. The footer indicates this document was processed by the DOJ Office of Government Relations.
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This document is page 9 of 239 from a legal filing in case 1:20-cr-00330-PAE, filed on April 16, 2021. It is a table of authorities, listing numerous legal case citations alphabetically from 'Miller v. Pate' to 'SEC v. TheStreet.com'. Each entry includes the case name, its legal reporter citation, and the page numbers where it is referenced within the main document.
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This document is page 7 of 239 (internally numbered 'vi') from a legal filing, Document 204 in case 1:20-cr-00330-PAE, filed on April 16, 2021. It is a table of cases, listing legal precedents with their citations and the page numbers where they are referenced in the main document. The footer includes a Department of Justice document identifier, DOJ-OGR-00002941.
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This document is page 8 of a legal filing (Document 307) from the criminal case against Ghislaine Maxwell, filed on June 25, 2021. The text argues against Maxwell's attempt to suppress deposition transcripts from a civil case, citing legal precedents (Oshatz, Wong, Knox) to establish that even if a protective order was modified, the testimony can be used, particularly in a perjury trial where the statements themselves are the crime. The government asserts that civil deposition testimony does not violate rights against self-incrimination in this context.
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